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REACH Identification of Uses for the Rubber Sector GENERAL RUBBER GOODS (GRG) Version 1.1 Brussels, 6 November 2009 Introduction and Downstream User Expectations In accordance with EC Regulation 1907/2006 Registration, Evaluation, and Authorisation of Chemicals (REACH) Article 37(2), a downstream user (DU) has the right to make a use known in writing to the manufacturer, importer, downstream user or distributor who supplies him with a substance on its own or in a preparation (registrant), making this an Identified Use. This aims to ensure that the registrants of the substance represent these uses in accordance with REACH Article 10(a) (iii) and if applicable, Article 14(4). On behalf of ETRMA members as downstream users (DU) of chemicals, this document provides identification of uses within General Rubber Goods manufacturing sector. The formulation/industrial use of these chemicals during the manufacturing process, and the professional use and service life cycle stages when used in finished articles are identified in this document. In making the use known, it is expected that sufficient information shall be provided to prepare an exposure scenario (ES), or if appropriate a use and exposure category, for that downstream use in the registrants chemical safety assessment (CSA). Communication of data to support the preparation of an ES will be provided by ETRMA later this year, as an integration to this communication. The update will be intended to provide sufficient information to perform a CSA, including all necessary information for Tier 1 assessment, but also other information for higher Tier assessment. If further iteration is required, ETRMA members recommend that registrants work with ETRMA through industry groups or consortia, to assure consistency and to minimize communications. Document validity This document is composed based on currently available ECHA guidance and it is subject to change following any future guidance revision or available information. For the most recent version of this document please refer to ETRMA website (www.etrma.org). For further information with respect to the above and future communications for use identification and exposure scenario generation for chemicals for the GRG manufacturing sector, please contact your national association representative or ETRMA: Lorenzo Zullo, +32 2 218 49 40, [email protected]

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REACH

Identification of Uses for the Rubber Sector GENERAL RUBBER GOODS (GRG)

Version 1.1

Brussels, 6 November 2009

Introduction and Downstream User Expectations

In accordance with EC Regulation 1907/2006 Registration, Evaluation, and Authorisation of Chemicals

(REACH) Article 37(2), a downstream user (DU) has the right to make a use known in writing to the

manufacturer, importer, downstream user or distributor who supplies him with a substance on its own

or in a preparation (registrant), making this an Identified Use. This aims to ensure that the registrants

of the substance represent these uses in accordance with REACH Article 10(a) (iii) and if applicable,

Article 14(4).

On behalf of ETRMA members as downstream users (DU) of chemicals, this document provides

identification of uses within General Rubber Goods manufacturing sector. The formulation/industrial

use of these chemicals during the manufacturing process, and the professional use and service life

cycle stages when used in finished articles are identified in this document.

In making the use known, it is expected that sufficient information shall be provided to prepare an

exposure scenario (ES), or if appropriate a use and exposure category, for that downstream use in the

registrants chemical safety assessment (CSA). Communication of data to support the preparation of an

ES will be provided by ETRMA later this year, as an integration to this communication. The update will

be intended to provide sufficient information to perform a CSA, including all necessary information for

Tier 1 assessment, but also other information for higher Tier assessment. If further iteration is

required, ETRMA members recommend that registrants work with ETRMA through industry groups or

consortia, to assure consistency and to minimize communications.

Document validity

This document is composed based on currently available ECHA guidance and it is subject to change

following any future guidance revision or available information. For the most recent version of this

document please refer to ETRMA website (www.etrma.org).

For further information with respect to the above and future communications for use identification

and exposure scenario generation for chemicals for the GRG manufacturing sector, please contact your

national association representative or ETRMA:

• Lorenzo Zullo, +32 2 218 49 40, [email protected]

Page 2 of 5

ETRMA Aisbl Tel +32 2 218 49 40

2/12 Avenue des Arts Fax +32 2 218 61 62

1210 Brussels Belgium www.etrma.org

EC Register : ID 6025320863-10

Use Descriptors Communication

In accordance with REACH Guidance on information requirements and chemical safety assessment,

Chapter R.12: Use descriptor system (Draft Version 2.0, 2009), the below table summarizes the use

descriptors valid for substances used in the GRG Sector, including the finished Articles, making these

Identified Uses.

SU - Sector of use

Main user groups

SU 3 Industrial use: uses of substances as such or in preparations at industrial site

Sectors of end-use

SU 11 Manufacture of rubber products

AC - Substances in articles AC 10 Rubber articles

GRG manufacturers may communicate additional AC codes to their suppliers depending on specific GRG

applications (i.e. AC1 Vehicles, AC 2 Machinery, mechanical appliances, electrical/electronic articles...)

01

- M

ast

ica

tio

n A

ge

nts

02

- V

ulc

an

isa

tio

n A

gts

03

- A

nti

de

gra

da

nts

04

- F

ille

rs a

nd

Pig

me

nts

05

- P

last

icis

ers

06

-

Pro

cess

ing

aid

s

07

- O

the

r a

ge

nts

(so

lve

nts

, e

mu

lsif

iers

,

rein

forc

ing

ag

en

ts.

Fo

r

de

tail

se

e T

ab

le 1

)

08

– L

ate

x c

he

mic

als

09

- R

ele

ase

Ag

en

ts

00

- O

the

rs

PC - Chemical product categories PC 9A X

PC 18 X

PC 24 X X

PC 32 X X X X X X X X X

For certain GRG applications PC1 (Adhesive, sealants) may be selected.

PROC - Process categories

PROC 5 X X X X X X X X X

PROC 7 X X X X X X X X X

PROC 8b X X X X X X X X X X

PROC 9 X X X X X X X X X X

PROC 10 X X X X X X X X X

PROC 12 X X X X X X X X X

PROC 13 X X X X X X X X X

PROC 14 X X X X X X X X X

PROC 21 X X X X X X X X X

ERC - Environmental release categories (To be used for Tier 1 assessment

Formulation and industrial use

ERC 3 X X X X X X X

ERC 4 X X X X

ERC 6d X X X X X

Service life

For covering environmental release during GRG service life the following ERCs may be communicated, depending on specific

applications:

• ERC 10A: Wide dispersive outdoor use of long-life articles and materials with low release (i.e. outdoor flooring, roofing...)

• ERC 11A: Wide dispersive indoor use of long-life articles and materials with low release (i.e. indoor flooring…)

Additional ERC codes may be considered for specific GRG applications.

Page 3 of 5

ETRMA Aisbl Tel +32 2 218 49 40

2/12 Avenue des Arts Fax +32 2 218 61 62

1210 Brussels Belgium www.etrma.org

EC Register : ID 6025320863-10

Substances and Classification Groups

A large number of substances are used in the GRG sector and these have been grouped according to

the TGD/OECD Classifications shown in the Table 1 below.

Table 1: TGD Classes of Substances used in the GRG Sector

TGD

Classes Description

TGD

Sub-classes Example Substances

01 Mastication Agents and

Peptisers

01-1 - activator N,N’-dithiodi-o-

phenylenedibenzamide

02 Vulcanisation Agents 02-1 - sulfur-containing cross-linking agents

02-2 - vulcanisation accelerator

02-3 - accelerator activator

02-4 - sulfur-free cross-linking agents

02-5 - coagents for sulfur-free cross-linking agents

02-6 - other cross-linking agents

02-7 - vulcanisation retarders

02-8 - scorch inhibitors

CBS, DPG

03 Antidegradants 03-1 - Antioxidants

03-2 - antifatigue agents

03-3 - Antiozonants

03-4 - light protection agents

03-5 - anti hydrolysis agents

03-6 - heat protection agents

03-7 - agents against metal poisoning

03-8 - deactivators

03-9 - reversion protection agents

03-10 - anticyclisation agents

03-11 - quencher

03-12 - other anti ageing agents

6PPD, Wax

04 Fillers and Pigments 04-1 - fillers

04-2 - pigments

Carbon Black, Silica, TiO2

05 Plasticisers 05-1 - plasticiser, natural

05-2 - plasticiser, synthetic

Oils – TDAE, MES, etc

06 Processing aids 06-1 - lubricants and flow improvers

06-2 - tackifier

06-3 - factices

06-4 - filler activator

06-5 - blowing agents

06-6 - bonding agents

06-7 - Stabiliser

Hydrocarbon Resins, Fatt

y Acids, Cobalt salts

Page 4 of 5

ETRMA Aisbl Tel +32 2 218 49 40

2/12 Avenue des Arts Fax +32 2 218 61 62

1210 Brussels Belgium www.etrma.org

EC Register : ID 6025320863-10

07 Other agents 07-1 - anticyclisation agents

07-2 - replastication agents

07-3 - emulsifier

07-4 - flame retardant

07-5 - solvents

07-6 - surface treatment agent

07-7 - hardeners

07-8 - odour agents

07-9 - antistatic agents

07-10 - microbiocides

07-11 - antitermite agents

07-12 - reinforcing agent

07-13 - homogeniser

Sulfates, Naphtha,

Hexane, HMMM

08 Latex chemicals 08-1 - dispersion agents

08-2 - emulsifier

08-3 - stabilizer

08-4 - wetting and foaming agents

08-5 - foam stabilizers

08-6 - thickeners

08-7 - coagulation agents

08-8 - preservatives

08-9 - vulcanisation chemicals

08-10 - anti ageing chemicals

08-11 - fillers

08-12 - plasticisers

09 Release agents 09-1 - ..for non-vulcanised rubber

09-2 - mould release agents

09-3 - mandrel release agents

Silicones

00 Others

In case of difficulties in identifying individual substances‘ categories, please refer to ETRMA, to your

national association representative or directly to your customer REACH contact for clarifications.

Page 5 of 5

ETRMA Aisbl Tel +32 2 218 49 40

2/12 Avenue des Arts Fax +32 2 218 61 62

1210 Brussels Belgium www.etrma.org

EC Register : ID 6025320863-10

Rubber Sector Process Schemes (GRG)

In support of the Uses communication, to illustrate the steps involved during DU usage of subject

chemicals during the formulation/industrial use stage, a high level schematic of the GRG

manufacturing processes and activities is shown in Table 2 below.

Table 2: Schematic of the GRG Manufacturing Process (Life Cycle Stage: Formulation and Industrial Use)

Disclaimer

The information contained in document is intended for guidance only whilst the information is provided in utmost good faith

and has been based on the best information currently available, is to be relied upon at the user ‘s own risk.

No representations or warranties are made with regards to its completeness or accuracy and no liability will be accepted for

damages of any nature whatsoever resulting from the use of or reliance on the information.

ANNEX: ECHA Guidance

ANNEX (ECHA GUIDANCE)

Full list of Use Descriptors (according to ECHA Guidance on information requirements and

chemical safety assessment, Chapter R.12: Use descriptor system - Draft Version 2.0, 2009.

1 European Commission, Competition: List of NACE Codes (2007.11.19);

http://ec.europa.eu/comm/competition/mergers/cases/index/nace_all.html

Main user groups

SU 3 Industrial uses: uses of substances as such or in preparations at industrial sites

SU 21 Consumer uses: Private households (= general public = consumers)

SU 22 Professional uses: Public domain (administration, education, entertainment, services, craftsmen)

Sectors of use [SU] – sectors of end-use NACE1 codes

SU1 Agriculture, forestry, fishery A

SU2a Mining, (without offshore industries) B

SU2b Offshore industries B 6

SU4 Manufacture of food products C 10,11

SU5 Manufacture of textiles, leather, fur C 13-15

Manufacture of wood and wood products C 16

SU6 Manufacture of pulp, paper and paper products C 17

SU7 Printing and reproduction of recorded media C 18

SU8 Manufacture of bulk, large scale chemicals (including petroleum products) C 19.2+20.1

SU9 Manufacture of fine chemicals C 20.2-20.6

SU 10 Formulation [mixing] of preparations and/or re-packaging (excluding alloys) C 20.3-20.5

SU11 Manufacture of rubber products C 22.1

SU12 Manufacture of plastics products, including compounding and conversion C 22.2

SU13 Manufacture of other non-metallic mineral products, e.g. plasters, cement C 23

SU14 Manufacture of basic metals, including alloys C 24

SU15 Manufacture of fabricated metal products, except machinery and equipment C 25

SU16 Manufacture of computer, electronic and optical products, electrical equipment C 26-27

SU17 General manufacturing, e.g. machinery, equipment, vehicles, other transport equipment. C 28-30,33

SU18 Manufacture of furniture C 31

SU19 Building and construction work F

SU20 Health services Q 86

SU23 Electricity, steam, gas water supply and sewage treatment C 35-37

SU24 Scientific research and development C72

Other

http://ec.europa.eu/comm/competition/mergers/cases/index/nace_all.html

ANNEX: ECHA Guidance

Chemical Product Category (PC)2

Category for describing market sectors (at supply

level) regarding all uses (workers and consumers)

Examples and explanations

PC0 Other products

PC1 Adhesives, sealants

PC2 Adsorbents

PC3 Air care products

PC4 Anti-Freeze and de-icing products

PC7 Base metals and alloys

PC8 Biocidal products (e.g. Disinfectants, pest control)

PC 35 should be assigned to disinfectants being used

as a component in a cleaning product

PC9a Coatings and paints, thinners, paint removers

PC9b Fillers, putties

PC9c Face and finger paints

PC11 Explosives

PC12 Fertilizers

PC13 Fuels

PC14

Metal surface treatment products, including galvanic

and electroplating products

This covers substances permanently binding with the

metal surface

PC15 Non-metal-surface treatment products Like for example treatment of walls before painting.

PC16 Heat transfer fluids

PC17 Hydraulic fluids

PC18 Ink and toners

PC19 Intermediate

PC20

Products such as ph-regulators, flocculants,

precipitants, neutralization agents

This category covers processing aids used in the

chemical industry

PC21 Laboratory chemicals

PC23

Leather tanning, dye, finishing, impregnation and care

products

PC24 Lubricants, greases, release products

PC25 Metal working fluids

PC26

Paper and board dye, finishing and impregnation

products: including bleaches and other processing

aids;

PC27 Plant protection products

PC28 Perfumes, fragrances

PC29 Pharmaceuticals

PC30 Photo-chemicals

PC31 Polishes and wax blends

PC32 Polymer preparations and compounds

2 The remark in the right column refers to consumer product (= preparation) categories particularly addressed in the

ConsExpo exposure estimation tool (1) or in the TRA exposure estimation tool (2).

ANNEX: ECHA Guidance

Chemical Product Category (PC)2

PC33 Semiconductors

PC34

Textile dyes, finishing and impregnating products;

including bleaches and other processing aids;

PC35

Washing and cleaning products (including solvent

based products)

PC36 Water softeners

PC37 Water treatment chemicals

PC38

Welding and soldering products (with flux coatings or

flux cores.), flux products

PC39 Cosmetics, personal care products

PC40 Extraction agents

Other (use UCN codes: see last row)

http://www.rivm.nl/en/healthanddisease/productsafety/ConsExpo.jsp

http://195.215.251.229/fmi/xsl/spin/SPIN/guide/menuguide.xsl?-db=spinguide&-lay=overview&-view#

ANNEX: ECHA Guidance

Process categories [PROC]

Process categories Examples and explanations

PROC 1

Use in closed process, no likelihood of

exposure

Use of the substances in high integrity contained system where

little potential exists for exposures, e.g. any sampling via

closed loop systems.

PROC 2 Use in closed, continuous process with

occasional controlled exposure

Continuous process but where the design philosophy is not

specifically aimed at minimizing emissions

It is not high integrity and occasional expose will arise e.g.

through maintenance, sampling and equipment breakages

PROC 3 Use in closed batch process (synthesis or

formulation)

Batch manufacture of a chemical or formulation where the

predominant handling is in a contained manner, e.g. through

enclosed transfers, but where some opportunity for contact

with chemicals occurs, e.g. through sampling

PROC 4 Use in batch and other process (synthesis)

where opportunity for exposure arises

Use in batch manufacture of a chemical where significant

opportunity for exposure arises, e.g. during charging, sampling

or discharge of material, and when the nature of the design is

likely to result in exposure.

PROC 5 Mixing or blending in batch processes for

formulation of preparations and articles

(multistage and/or significant contact)

Manufacture or formulation of chemical products or articles

using technologies related to mixing and blending of solid or

liquid materials, and where the process is in stages and

provides the opportunity for significant contact at any stage.

PROC 6 Calendering operations

Processing of product matrix Calendering at elevated

temperature an large exposed surface

PROC 7 Industrial spraying Air dispersive techniques

Spraying for surface coating, adhesives, polishes/cleaners, air

care products, sandblasting;

Substances can be inhaled as aerosols. The energy of the

aerosol particles may require advanced exposure controls; in

case of coating, overspray may lead to waste water and waste.

PROC 8a Transfer of substance or preparation

(charging/discharging) from/to

vessels/large containers at non-dedicated

facilities

Sampling, loading, filling, transfer, dumping, bagging in non-

dedicated facilities. Exposure related to dust, vapour, aerosols

or spillage, and cleaning of equipment to be expected.

PROC 8b Transfer of substance or preparation

(charging/discharging) from/to

vessels/large containers at dedicated

facilities

Sampling, loading, filling, transfer, dumping, bagging in

dedicated facilities. Exposure related to dust, vapour, aerosols

or spillage, and cleaning of equipment to be expected.

PROC 9 Transfer of substance or preparation into

small containers (dedicated filling line,

including weighing)

Filling lines specifically designed to both capture vapour and

aerosol emissions and minimise spillage

PROC 10 Roller application or brushing

Low energy spreading of e.g. coatings.

Including cleaning of surfaces. Substance can be inhaled as

vapours, skin contact can occur through droplets, splashes,

working with wipes and handling of treated surfaces.

PROC 11 Non industrial spraying

Air dispersive techniques

Spraying for surface coating, adhesives, polishes/cleaners, air

ANNEX: ECHA Guidance

Process categories [PROC]

Process categories Examples and explanations

care products, sandblasting

Substances can be inhaled as aerosols. The energy of the

aerosol particles may require advanced exposure controls;

PROC 12 Use of blowing agents in manufacture of

foam

PROC 13 Treatment of articles by dipping and

pouring

Immersion operations

Treatment of articles by dipping, pouring, immersing, soaking,

washing out or washing in substances; including cold

formation or resin type matrix. Includes handling of treated

objects (e.g. after dying, plating,).

Substance is applied to a surface by low energy techniques

such as dipping the article into a bath or pouring a preparation

onto a surface

PROC 14 Production of preparations or articles by

tabletting, compression, extrusion,

pelletisation

PROC 15 Use as laboratory reagent

Use of substances at small scale laboratory (< 1 l or 1 kg).

Larger laboratories and R+D installations should be treated as

industrial processes.

PROC 16 Using material as fuel sources, limited

exposure to unburned product to be

expected

Covers the use of material as fuel sources (including additives)

where limited exposure to the product in its unburned form is

expected. Does not cover exposure as a consequence of

spillage or combustion.

PROC 17 Lubrication at high energy conditions and

in partly open process

Lubrication at high energy conditions (temperature, friction)

between moving parts and substance; significant part of

process is open to workers.

The metal working fluid may form aerosols or fumes due to

rapidly moving metal parts;

PROC 18 Greasing at high energy conditions

Use as lubricant where significant energy or temperature is

applied between the substance and the moving parts.

PROC 19 Hand-mixing with intimate contact and

only PPE available.

Addresses occupations where intimate and intentional contact

with substances occurs without any specific exposure controls

other than PPE.

PROC 20 Heat and pressure transfer fluids in

dispersive, professional use but closed

systems

Motor and engine oils, brake fluids

Also in these applications, the lubricant may be exposed to

high energy conditions and chemical reactions may take place

during use. Exhausted fluids need to be disposed of as waste.

Repair and maintenance may lead to skin contact.

PROC 21 Low energy manipulation of substances

bound in materials and/or articles

Manual cutting, cold rolling or assembly/disassembly of

material/article (including metals in massive form), possibly

resulting in the release of fibres, rubber fumes, metal fumes or

dust;

PROC 22 Potentially closed processing operations

with minerals/metals at elevated

temperature

Industrial setting

Activities at smelters, furnaces, refineries, coke ovens.

Exposure related to dust and fumes to be expected. Emission

from direct cooling may be relevant.

ANNEX: ECHA Guidance

Process categories [PROC]

Process categories Examples and explanations

PROC 23 Open processing and transfer operations

with minerals/metals at elevated

temperature

Sand and die casting, tapping and casting melted solids,

drossing of melted solids, hot dip galvanising, raking of

melted solids in paving;

Exposure related to dust and fumes to be expected.

PROC 24 High (mechanical) energy work-up of

substances bound in materials and/or

articles

Substantial thermal or kinetic energy applied to substance

(including metals in massive form) by hot rolling/forming,

grinding, mechanical cutting, drilling or sanding. Exposure is

predominantly expected to be to dust. Dust or aerosol emission

as result of direct cooling may be expected.

PROC 25 Other hot work operations with metals Welding, soldering, gouging, brazing, flame cutting

Exposure is predominantly expected to fumes and gases.

PROC 26 Handling of solid inorganic substances at

ambient temperature (no corresponding

TRA entry)

Transfer and handling of ores, concentrates, raw metal oxides

and scrap; packaging, un-packaging, mixing/blending and

weighing of metal powders or other minerals;

PROC 27 Production of metal powders (no

corresponding TRA entry)

Production of metal powders by hot (atomisation, dry

dispersion) and wet (electrolysis, wet dispersion) metallurgical

processes

Other process or activity, please specify;

ERC

NUMBER

Name Description

ERC 1 Manufacture of substances Manufacture of organic and inorganic substances in chemical,

petrochemical, primary metals and minerals industry including

intermediates, monomers using continuous processes or batch

processes applying dedicated or multi-purpose equipment, either

technically controlled or operated by manual interventions

ERC 2 Formulation of preparations Mixing and blending of substances into (chemical) preparations in

all types of formulating industries, such as paints and do-it-yourself

products, pigment paste, fuels, household products (cleaning

products), lubricants etc.

ERC 3 Formulation in materials Mixing or blending of substances which will be physically or

chemically bound into or onto a matrix (material) such as plastics

additives in master batches or plastic compounds. For instance a

plasticizers or stabilizers in PVC master-batches or products, crystal

growth regulator in photographic films etc.

ERC 4 Industrial use of processing

aids in processes and products,

not becoming part of articles

Industrial use of processing aids in continuous processes or batch

processes applying dedicated or multi-purpose equipment, either

technically controlled or operated by manual interventions. For

example, solvents used in chemical reactions or the ‘use’ of solvents

during the application of paints, lubricants in metal working fluids,

anti-set off agents in polymer moulding/casting

ERC 5 Industrial use resulting in

inclusion into or onto a matrix

Industrial use of substances as such or in preparations (non-

processing aids), which will be physically or chemically bound into

or onto a matrix (material) such as binding agent in paints and

coatings or adhesives, dyes in textile fabrics and leather products,

metals in coatings applied through plating and galvanizing

processes. The category covers substances in articles with a

ANNEX: ECHA Guidance

ERC

NUMBER

Name Description

particular function and also substances remaining in the article after

having been used as processing aid in an earlier life cycle stage (e.g.

heat stabilisers in plastic processing)..

ERC 6A Industrial use resulting in

manufacture of another

substance (use of

intermediates)

Use of intermediates in primarily the chemical industry using

continuous processes or batch processes applying dedicated or

multi-purpose equipment, either technically controlled or operated

by manual interventions, for the synthesis (manufacture) of other

substances. For instance the use of chemical building blocks

(feedstock) in the synthesis of agrochemicals, pharmaceuticals,

monomers etc.

ERC 6B Industrial use of reactive

processing aids

Industrial use of reactive processing aids in continuous processes or

batch processes applying dedicated or multi-purpose equipment,

either technically controlled or operated by manual interventions.

For example the use of bleaching agents in the paper industry.

ERC 6C Industrial use of monomers for

manufacture of thermoplastics

Industrial use of monomers in the production of polymers, plastics

(thermoplastics), polymerization processes. For example the use of

vinyl chloride monomer in the production of PVC

ERC 6D Industrial use of process

regulators for polymerisation

processes in production of

resins, rubbers, polymers

Industrial use of chemicals (cross-linking agents, curing agents) in

the production of thermosets and rubbers, polymer processing. For

instance the use of styrene in polyester production or vulcanization

agents in the production of rubbers

ERC 7 Industrial use of substances in

closed systems

Industrial use of substances in closed systems. Use in closed

equipment, such as the use of liquids in hydraulic systems, cooling

liquids in refrigerators and lubricants in engines and dielectric fluids

in electric transformers and oil in heat exchangers. No intended

contact between functional fluids and products foreseen, and thus

low emissions via waste water and waste air to be expected.

ERC 8A Wide dispersive indoor use of

processing aids in open

systems

Indoor use of processing aids by the public at large or professional

use. Use (usually) results in direct release into the

environment/sewage system, for example, detergents in fabric

washing, machine wash liquids and lavatory cleaners, automotive

and bicycle care products (polishes, lubricants, de-icers), solvents in

paints and adhesives or fragrances and aerosol propellants in air

fresheners.

ERC 8B Wide dispersive indoor use of

reactive substances in open

systems

Indoor use of reactive substances by the public at large or

professional use. Use (usually) results in direct release into the

environment, for example, sodium hypochlorite in lavatory cleaners,

bleaching agents in fabric washing products, hydrogen peroxide in

dental care products.

ERC 8C Wide dispersive indoor use

resulting in inclusion into or

onto a matrix

Indoor use of substances (non-processing aids) by the public at large

or professional use, which will be physically or chemically bound

into or onto a matrix (material) such as binding agent in paints and

coatings or adhesives, dyeing of textile fabrics.

ERC 8D Wide dispersive outdoor use of

processing aids in open

systems

Outdoor use of processing aids by the public at large or professional

use. Use (usually) results in direct release into the environment, for

example, automotive and bicycle care products (polishes, lubricants,

de-icers, detergents), solvents in paints and adhesives.

ANNEX: ECHA Guidance

ERC

NUMBER

Name Description

ERC 8E Wide dispersive outdoor use of

reactive substances in open

systems

Outdoor use of reactive substances by the public at large or

professional use. Use (usually) results in direct release into the

environment, for example, the use of sodium hypochlorite or

hydrogen peroxide for surface cleaning (building materials)

ERC 8F Wide dispersive outdoor use

resulting in inclusion into or

onto a matrix

Outdoor use of substances (non-processing aids) by the public at

large or professional use, which will be physically or chemically

bound into or onto a matrix (material) such as binding agent in

paints and coatings or adhesives.

ERC 9A Wide dispersive indoor use of

substances in closed systems

Indoor use of substances by the public at large or professional

(small scale) use in closed systems. Use in closed equipment, such

as the use of cooling liquids in refrigerators, oil-based electric

heaters.

ERC 9B Wide dispersive outdoor use of

substances in closed systems

Outdoor use of substances by the public at large or professional

(small scale) use in closed systems. Use in closed equipment, such

as the use of hydraulic liquids in automotive suspension, lubricants

in motor oil and break fluids in automotive brake systems.

ERC 10A Wide dispersive outdoor use of

long-life articles and materials

with low release

Low release of substances included into or onto articles and

materials during their service life in outdoor use, such as metal,

wooden and plastic construction and building materials (gutters,

drains, frames etc.)

ERC 10B Wide dispersive outdoor use of

long-life articles and materials

with high or intended release

(including abrasive processing)

Substances included into or onto articles and materials with high or

intended release during their service life from outdoor use. Such as

tyres, treated wooden products, treated textile and fabric like sun

blinds and parasols and furniture, zinc anodes in commercial

shipping and pleasure craft, and brake pads in trucks or cars. This

also includes releases from the article matrix as a result of

processing by workers. These are processes typically related to

PROC 21, 24, 25, for example: Sanding of buildings (bridges,

facades) or vehicles (ships).

ERC 11A Wide dispersive indoor use of

long-life articles and materials

with low release

Low release of substances included into or onto articles and

materials during their service life from indoor use. For example,

flooring, furniture, toys, construction materials, curtains, footwear,

leather products, paper and cardboard products (magazines, books,

news paper and packaging paper), electronic equipment (casing)

ERC 11B Wide dispersive indoor use of

long-life articles and materials

with high or intended release

(including abrasive processing)

Substances included into or onto articles and materials with high or

intended release during their service life from indoor use. For

example: release from fabrics, textiles (clothing, floor rugs) during

washing. This also includes releases from the article matrix as a

result of processing by workers. These are processes typically

related to PROC 21, 24, 25. For example removal of indoor paints.

ERC 12 Industrial processing of

articles with abrasive

techniques (high release)

Substances included into or onto articles and materials are released

from the article matrix as a result of processing by workers. These

are processes typically related to PROC 21, 24, 25, were the

removal of material is intended. For example metal cutting in

engineering industries or centralised paint stripping in aircraft

industry

Other environmental

characteristics; please specify

ANNEX: ECHA Guidance

Article categories, no release intended [AC]

Article categories (and non exhaustive examples) for describing the type of article

in which the substance is contained during service life and waste life

Suitable TARIC

chapters

Categories of complex articles

AC 1 Vehicles 86-89

Trucks, passenger cars and motor cycles, bicycles, tricycles and associated

transport equipment

Other vehicles: Railway, aircraft, vessels, boats

AC 2 Machinery, mechanical appliances, electrical/electronic articles 84/85

Machinery and mechanical appliances ,

Electrical and electronic articles, e.g. computers, video and audio recording,

communication equipment; lamps and lightening; cameras; refrigerator, dish

washer, washing machines

AC 3 Electrical batteries and accumulators 8506/07

Categories of material based articles

AC 4 Stone, plaster, cement, glass and ceramic articles 68/69/70

Glass and ceramic article: e.g. dinner ware, drinking glasses, pots, pans, food

storage containers

Construction and isolation articles

Natural or artificial abrasive powder or grain, on a base of textile material, of

paper, of paperboard or of other materials.

AC 5 Fabrics, textiles and apparel 50-63, 94/95

Clothing

Bedding, mattress

Curtains, upholstery, carpeting/flooring, car seats

Textile Toys

AC 6 Leather and fur articles 41-43, 64, 94

Gloves, purse, wallet,

Foot wear

Furniture

AC 7 Metal articles 71, 73-83, 95

Cutlery, cooking utensils, pots, pans,

Jewellery

Toys

Furniture

Construction articles

AC 8 Paper articles 48-49

Paper articles: tissue, towels, disposable dinnerware, nappies, feminine hygiene

products, adult incontinence products;

Paper articles for writing, office paper

Printed paper articles: e.g. newspapers, books, magazines, printed photographs

ANNEX: ECHA Guidance

Article categories, no release intended [AC]

Article categories (and non exhaustive examples) for describing the type of article

in which the substance is contained during service life and waste life

Suitable TARIC

chapters

Wallpaper

AC 10 Rubber articles 40, 64, 95

Rubber tyres

Rubber flooring

Rubber gloves

Rubber footwear

Rubber toys

AC 11 Wood and straw articles 44-46, 94/95

Wooden flooring

Wooden furniture

Wooden toys

Wooden construction articles

AC 13 Plastic articles 39, 94/95, 85/86

Plastic dinner ware, food storage, food packaging, baby bottles

Plastic flooring

Plastic toys

Plastic furniture

Small plastic articles of daily use e.g. ball pen, PC, mobile phone

Plastic construction articles

Other (use TARIC codes: see last row)

http://ec.europa.eu/taxation_customs/dds/tarhome_en.htm

Use descriptor for articles with intended release of substances

Descriptor based on an indicative list of examples

AC30 Other articles with intended release of substances, please specify3

AC31 Scented clothes

AC32 Scented eraser

AC33 Entry has been removed after the REACH CA meeting in March 2008.

AC34 Scented Toys

AC35 Scented paper articles

AC36 Scented CD

AC38 Packaging material for metal parts, releasing grease/corrosion inhibitors